This week we look at:

• Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP)

• Strict Enforcement of Tax Refund Statutes of Limitations

• Employee Retention Credit (ERC) Refund Claims & Pleading Standards

• Pandemic-Era Persistence of New York's Convenience of the Employer Rule

• Invalidity of Treasury Regulation Section 1.951A-2(c)(5)

• Non-Shareholder Capital Contributions vs. Compensation

• Final Section 1035 Exchange & Corporate Reorganization Regulations

• Reclassification of Abusive CRAT Structures as Listed Transactions

• The National Taxpayer Advocate's Perspective on AEP

This week we look at:

• Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2.
• Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026.
• Business Tax Account: Modernized self-service portal expands features but requires active annual maintenance.
• Litigation Legal Fees: FCRA settlements are taxable gross income without above-the-line deduction.
• Corporate Reorganizations: Tax Court invalidates regulation limiting 100% DRD in post-Loper Bright era.
• ERC Litigation Realities: Exhaustion loophole rejected; notice pleading standards approved in refund suits.
• Conservation Easements: Valuation must be grounded in immediate local market demand, not speculation.

This week we look at:

• Unpacking the Saver's Match: Technical Guidance and Operational Frameworks Under Notice 2026-48
• Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds
• The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit's Final Ruling in Boechler, P.C.
• Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26
• The Perpetual Burden of Carryover Substantiation: AMT Credits and Recordkeeping in Beacom v. Commissioner
• Equitable Tolling of Tax Court Filing Deadlines: Maniktala v. Commissioner (8th Cir.)
• Standardizing Retirement Plan Rollovers and Trustee-to-Trustee Transfers under SECURE 2.0: Notice 2026-49
• Unmasking the $70 Million Dubai Fraud: Section 165 Theft Loss Deductions in Deutsch v. Commissioner
• Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations (REG-103844-26)
• Rehearing Reversal: The Fifth Circuit's Management Test for the Limited Partner Exception (K Alain, L.L.L.P.)
• The Crucial Role of Highest and Best Use in Conservation Easement Valuations: Evans v. Commissioner